Cayman Islands: CIMA Fee Adjustments for Mutual and Private Funds Effective 1 January 2026

The Cayman Islands Government has implemented changes to the annual fee structure for investment funds regulated under the Mutual Funds Act (2025 Revision) and Private Funds Act (2025 Revision). These adjustments are effective 1 January 2026.

Old Structure (2025)

• Annual fee (based on number of sub‑funds), payable at the start of the year.
• Separate annual return fee of CI$300 (USD366), payable mid‑year.
• For alternative investment vehicles or sub‑funds under the Private Funds Act: CI$150 (USD183).

New Structure (from 2026)

• The separate annual return filing fee is abolished and now incorporated into the increased annual fund fee, payable at the start of the year.
• Annual fund fee increases for 2026:
• Mutual Funds & sub-funds: uplifted by CI$450 (USD549) per fund/sub-fund.
• Private Funds: uplifted by CI$450 (USD549).
• Private Funds sub‑funds: uplifted by CI$225 (USD275) per alternative investment vehicles and related structures

By consolidating the annual return fee into the annual fund fee, the goal of Cayman Islands Monetary Authority (CIMA) aim is to simplify the regulatory framework, reduce duplication and align Cayman’s supervisory practices with international standards. This change ensures that the cost of regulatory oversight is proportionately reflected in a single annual charge, while improving transparency and administrative efficiency.

Fee Payment and Penalty Arrangements

To ease the transition, CIMA has confirmed that no penalties will be applied until after 15 February 2026. Regulated entities must, however, ensure that at least the 2025 fee amounts are remitted by the statutory deadline of 15 January 2026. From 16 February 2026, penalties will be applied to any outstanding balances. Regulated entities are encouraged to settle the adjusted 2026 fees promptly to avoid penalty exposure and to remain fully compliant with the prescribed timelines.

Next Steps for Marbury Clients

For affected regulated entity clients, the increase relates solely to this consolidation and uplift of the annual fund fee. As most agents, including Marbury, already invoiced the 2026 annual return fee together with the 2026 annual fee in an annual invoice to clients issued in late 2025, an adjustment invoice for the balance of the new 2026 fee will be issued in the coming days. 

For any related queries, please contact your usual Marbury relationship manager or info@marburys.com.

For further details, see the following legislative references:

• The Mutual Funds (Annual Returns) (Amendment) Regulations, 2025;
• The Mutual Funds (Fees) (Amendment) Regulations, 2025;
• The Private Funds (Annual Returns) (Amendment) Regulations, 2025;
• The Private Funds (Fees) (Amendment) Regulations, 2025;